SEC Exam Priorities for 2026

The SEC’s Division of Examinations (commonly known as EXAMS) is the oversight branch of the Securities and Exchange Commission that’s charged with ensuring registrants adhere to regulatory standards. Established advisors can expect to be examined roughly every four to seven years, which should allow you plenty of time to prepare. Reviewing SEC exam priorities for the current year can offer insight on which compliance areas you may need to focus on. For full details on these priorities, see the SEC’s summary.¹ 

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Investment Advisors

Compared to 2025’s exam priorities, little has changed for investment advisors. In 2026, the SEC is chiefly concerned with ensuring registrants are:

• Adhering to a fiduciary code of conduct
• Making proper disclosures regarding conflicts of interest
• Recommending products that serve the best interests of clients

The SEC is also taking an interest in the investment recommendations registered advisors make. Specific attention is being paid to:

• Alternative and complex investments
• Investments that carry higher costs, either in commissions or fees
• Recommendations to older investors and retirement savers
• Investment products that are more sensitive to market volatility

Certain advisors are considered to be higher-risk in the SEC exam priorities for 2026. They include dual-registered advisors, advisors who use third-party vendors to access client accounts and advisors who have merged or consolidated with, or have been acquired by another firm. If you hold any of these statuses or anticipate a merger in the year ahead, be aware that you may be prioritized for examination. 

The effectiveness of advisor compliance programs is another exam priority. Specifically, the SEC is concerned with how compliance programs are being implemented and enforced. If you haven’t reviewed your compliance policies recently, that may be something to direct attention to in the coming year. 

Note: Newly registered advisors and advisors who have never been examined take precedence for examination over established firms. 

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Investment Companies

SEC exam priorities for 2026 also include investment companies and how they deliver services to retail investors, particularly those who are saving for retirement. Examinations of registered investment companies (RICs) will include: 

• Compliance programs
• Disclosures
• Required filings
• Governance practices
• Operations (specifically fund fees and expenses and portfolio management practices)

Special areas of interest for examiners include RICs that participate in mergers and acquisitions, investment companies that use complex investment strategies or maintain a substantial volume of illiquid holdings and firms that utilize “novel” investment strategies or products. 

As with investment advisors, the SEC puts new RICs and those that have yet to be examined at the head of the line. 

Broker-Dealers

The main focus for broker-dealers in 2026 is compliance with the net-capital rule, the customer protection rule and related internal processes. Other areas of review include:

• Timeliness of required filings
• Operational resiliency
• Supervision and monitoring of third-party vendors
• Credit risk, market risk and liquidity risk
• Cash sweep programs and core brokerage activities

The SEC continues to focus on fixed income trading practices associated with extended-hours trading and municipal securities. Broker-dealers may be examined on routing and order execution practices, as well as the use of alternative trading systems. 

On the retail side, exam priorities include practices related to Regulation Best Interest (BI) and how broker-dealers are recommending investments. Complex and alternative investments may come under closer scrutiny, along with 529 plans, private placements and investments with more complicated fee structures. 

Broker-dealers should expect examiners to review their customer relationship summary (Form CRS) for accuracy and to ensure that all required disclosures have been made. 

Self-Regulatory Organizations

National securities exchanges and organizations like FINRA and the Municipal Securities Rulemaking Board will be examined to ensure they enforce compliance with their rules and federal securities laws. Exams may focus on regulatory programs and participation in National Market System plans. 

SEC exam priorities don’t list any specific areas of focus for FINRA oversight. Generally, the SEC reviews FINRA’s major regulatory programs and makes recommendations on how to improve them. It does the same with the MSRB.

Clearing Agencies

The Dodd-Frank Act requires the SEC to examine registered clearing agencies at least once annually. Exams focus on risk management frameworks, including liquidity, margin systems and default management. The SEC assesses their compliance with the Securities Exchange Act and the effectiveness of their remediation efforts for prior deficiencies.

The SEC also examines registered clearing agencies that have not been deemed systemically important. The purpose of these examinations centers on assessing risk and identifying operational areas that present potential weak spots. 

Other Market Participants

Municipal advisors, transfer agents, security-based swap dealers and funding portals are examined for compliance with applicable regulations, fiduciary duties and risk management practices. This includes evaluations of their policies, procedures and operational controls.

For 2026, the SEC is looking at:

• Whether municipal advisors have complied with MSRB Rule G-42, which establishes core standards of conduct
• Compliance with filing requirements
• Adherence to fiduciary standards of conduct

Transfer agents will be examined in the areas of recordkeeping and retention, safeguarding of funds and securities and adherence to filing requirements. Recordkeeping is also a primary focus for funding portals. 

Risk Areas Impacting Various Market Participants

The SEC identifies key risk areas that may have far-reaching impacts on market participants. For 2026, critical risks include:

• Cybersecurity, both in the context of safeguarding client data and managing operational risk
• Regulations S-ID and S-P, which deal with identity theft prevention, internal data controls and oversight of third-party vendors
• Emerging financial technology, specifically the use of artificial intelligence (AI) in the advisory space
• Regulation systems compliance and integrity
• Anti-money laundering (AML) rules compliance 

Bottom Line

Every year the SEC publishes its examination priorities for regulated entities. This year, it has published its 2026 exam priorities so that investment advisors, broker-dealers and investors can begin to prepare for the next round of annual examinations.

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